The OECD model convention, 1996 and beyond : income of professional partnerships, employees as permanent establishments : proceedings of a seminar held in Geneva in 1996 during the 50th Congress of the International Fiscal Association

書誌事項

The OECD model convention, 1996 and beyond : income of professional partnerships, employees as permanent establishments : proceedings of a seminar held in Geneva in 1996 during the 50th Congress of the International Fiscal Association

[edited by International Fiscal Association]

(IFA Congress seminar series, v. 21c)

Kluwer Law International, c1998

  • : pbk

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注記

Chair: Klaus Vogel (Germany)

内容説明・目次

内容説明

The seminar on development and selected topics of the OECD Model Tax Convention, organized jointly by OECD and IFA, has become a much-appreciated regular feature of IFA Congresses. The present publication gives an account of the papers delivered and the discussions held in the context of this seminar at IFA's Congress in Geneva in September 1996. The first and foremost part of the seminar was constituted as usual by reports delivered by Mr Owens and Mr Luthi on current and upcoming work of the Committee on Fiscal Affairs and in particular, its Working Party No. 1, which is in charge of the Model Convention. For the subsequent panel two subjects regarding interpretation of that Convention were selected, one under its article 14, the other under its article 7.

目次

  • Introductory Notes. Works of the OECD I
  • J. Owens. Works of the OECD II
  • D. Lutti. Allocation of Profits under Article 14. To Which Extent do Employees Assigned to a Subsidiary Constitute a Permanent Establishment of the Parent Company? Appendix 1: The OECD Committee on Fiscal Affairs. Appendix 2: Outline on Article 14. Appendix 3: Outline on Employees as a Permanent Establishment. Appendix 4: The Origins of OECD Model Articles 7, 14 and 15.

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